Health hazards in construction

In Oregon, construction industry employers receive more citations for violations of lead, asbestos, hazard communication, and respiratory protection standards than other health standards. Typically, one or two paragraphs in each standard account for most of the citations.

This is the first in a series of articles in the Construction Depot that explain the requirements of each standard's most frequently cited paragraphs.

Lead: The exposure assessment [1926.62(d)]

Your employees are about to start a major remodeling project on an older home. Do you know how to assess their exposure?

You need to determine if lead is present in the home. If the home was built before 1978, it's possible that lead paint is present. To be certain that lead is present, you should do one of the following: hire a certified lead-based paint inspector or a risk assessor, have samples of the paint analyzed by an environmental lab, or use a lead check stick (lead check sticks can be helpful, but they may not be 100 percent reliable).

If lead is present, you need to determine whether your employees' work will expose them to lead at or above what's called the action level (30 micrograms per cubic meter of air averaged over eight hours). The most common way to do this is to sample the air your employees breathe with air-monitoring equipment while they are working. You can do air monitoring yourself if you know how to do it and if you have the right equipment, which you can rent. You can also hire a consultant, or your workers' compensation insurance carrier may be able to help.

There's a big problem, however, with monitoring your employees' exposure to lead while they are working: they could be overexposed to lead – and you don't want that to happen unless they are protected.

So, while you are doing air monitoring, you must assume that your employees are exposed to lead above the action level and you must do a minimum of SIX things (known as interim protective measures) to ensure that your employees are protected. These six things are:

Provide your employees with appropriate respirators.

Provide your employees with appropriate protective clothing.

Provide clean areas for your employees to change and store their clothing.

Provide hand-washing facilities for your employees.

Ensure that your employees have their blood sampled for lead.

Provide training for your employees that covers lead health hazards and all parts of the lead standard, 1926.62.

If your employees do any of the following jobs, you must also do the minimum six protective measures.

Manual demolition of structures such as dry wall, windows, and siding

Manual scraping of dry materials

Manual sanding

Sanding with a dust collection system

Cutting with a torch

Heat gun work

Spray painting

Sanding without dust collection systems

Abrasive blasting

Lead burning

Torch burning

Welding

Your employees' air monitoring results will tell you the level of their exposure to lead while they are doing the remodeling work. If they are exposed at or above the action level, you must provide protective measures, including additional air monitoring, medical surveillance, and training.

You must also ensure that your employees are not exposed to lead at levels greater than 50 micrograms per cubic meter of air averaged over eight hours – that's the maximum permissible exposure limit (PEL). You can use engineering and administrative controls to keep your employees' exposures to lead at or below the PEL.

Engineering controls include tools that can reduce your employees' exposure to lead. Using a sander attached to a HEPA vacuum to reduce dust is an example. Administrative controls change employees' work practices and temporarily reduce their exposures. Prohibiting workers from working in areas that expose them to lead above the action level is an example. If engineering and administrative controls are not effective, then your employees must also use appropriate respirators.